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HomeMy WebLinkAboutMemo - Mail Packet - 10/19/2021 - Memorandum From Cassie Archuleta Re: Oil And Gas - Regulatory Process Update 1 Environmental Services 222 Laporte Ave Fort Collins, CO 80522 970.221.6600 970.224.6177 - fax fcgov.com MEMORANDUM DATE: October 12, 2021 TO: Mayor and Councilmembers THRU: Kelly DiMartino, Interim City Manager Kyle Stannert, Deputy City Manager Jacqueline Kozak-Thiel, Chief Sustainability Officer Lindsay Ex, Environmental Services Director FROM: Cassie Archuleta, Air Quality Program Manager SUBJECT: Oil and Gas Regulatory Process Update The purpose of this memorandum is to provide an informational update regarding progress on the development of local regulations for oil and gas operations. Bottom Line The City is continuing to work towards adopting comprehensive regulations for oil and gas operations, per new local authority granted through the adoption of Senate Bill 19-181. Additionally, the State and County have recently completed a series of rulemakings that established new regulatory frameworks. In alignment with Council and community feedback, local regulations are being developed to go beyond new State and County regulations to eliminate or minimize surface impacts from existing and new development. Quarterly updates will be provided as regulations are developed, and a Council Work Session is scheduled for March 2022. Background The adoption of Senate Bill 19-181 in April 2019 prompted a comprehensive rulemaking overhaul at the State level and marked In Fort Collins, surface access for oil and gas development is already limited by infill and will become increasingly so as the City continues to grow. Existing oil and gas development includes one operator with ten (10) active wells in a small oilfield in northeast Fort Collins. Progress Update The Colorado Oil and Gas Conservation Commission (COGCC) and many local jurisdictions have undertaken broad efforts to update regional and local oil and gas regulations. Newly adopted State regulations set the floor for potential new City regulations related to surface use, and recently adopted Larimer County regulations apply and City owned property outside of City limits. Currently, City staff are developing draft regulations and continuing to participate in ongoing COGCC rulemakings. General concepts and objectives guiding rule development are included in Attachment A, as informed by Council and community feedback to date. Key elements of this feedback have included: Public engagement, which has included open houses, and numerous meetings and conversations with City Boards, environmental and neighborhood groups; A January 2021 Work Session, where Councilmembers indicated support for the use of industrial zoning requirements and setbacks for new oil and gas permits, which will effectively eliminate potential space for new wells within City limits; Engagement with Larimer County planners as new regulations were developed; and Conversations with the current operator and industry representatives from the American Petroleum Institute (API) and the Colorado Oil and Gas Association (COGA). 2 Existing Operations The lone operator in Fort Collins, Prospect Energy, has submitted a permit for new activity at an existing well outside of City limits, and within the Fort Collins GMA. This would not include drilling of a new well but would involve hydraulic fracturing and could potentially extend the life of existing wells. The City and Larimer County are in conversations with the COGCC to determine potential City and County authority for additional development at these existing wells. If there are options to influence this process, such as an opportunity to annex the property or defer annexation, staff will bring them to Council for consideration. Timeline and Next Steps Per concepts listed in Attachment A, the City is working with a consultant to draft code and best management practices for Council consideration. Process steps include: November December, 2021; internal review January February 2022; additional outreach including community members, boards, commissions and the operator March 2022; Council Work Session Additionally, staff will continue to provide quarterly progress updates via memoranda. CC: Kelly Smith, Senior Environmental Planner Rebecca Everette, Planning Manager Paul Sizemore, CDNS Director Caryn Champine, PDT Director 3 ATTACHMENT A Oil and Gas Regulations - Conceptual Elements and Objectives Item/Element Objective Applicable/Anticipated Regulatory Placement Siting New Development New Development within City limits Limit to Industrial zones and residential buildings. Also evaluate setbacks for water bodies and other development. Land Use Code New Development within Grown Management Area (GMA) Limit new development to maximum extent possible. Work within State and County authority. Larimer County regulations New Development within City-owned Natural Areas (outside of City limits) Limit new development to maximum extent possible. Work within State and County authority. Larimer County regulations Reverse/reciprocal setbacks (distance for new homes from existing wells) Updated in 2018 to align with setbacks for new wells. Need to align with new COGCC setbacks and GMA considerations. Land Use Code Permitting/Approval Process Public Review/Engagement Require robust public notification and review process. Land Use Code Surface Owner Agreements Include as part of permitting process. Include in application requirements Plans required (e.g., air quality, transportation, noise, emergency response, etc.) Local review of plans to meet or exceed State, County and City standards. Include in application requirements Financial assurances Ensure sufficient financial assurances for potential future costs to plug, reclaim and remediate a well site. Documentation required annually Operational Standards/ Management Practices Air Quality, Water Quality, Natural Resource Protection, Visual and Noise Mitigation, etc. Define standards and best practices that prevent nuisances and potential health and environmental impacts. Develop Best Management Practices (BMPs) to be referenced in City Code